ML20038A497
| ML20038A497 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/16/1976 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20038A496 | List: |
| References | |
| 50-247-76-26, 50-286-76-28, NUDOCS 8111090280 | |
| Download: ML20038A497 (3) | |
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License No. DPR-26 License No. DPR-64 APPENDIX A NOTICE OF VIOLATION
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..g Based on the results of an NRC inspection conducted on October 26-29,
.I 1976, it appears that certain of ycur activities were not conducted in
.; P full compliance with conditions of your NRC License Nos. DPR-26 and DPR-i (
64 as indicated below. Top Unit 2, items A, B, C and D are Infractions
,c d and item E is a Deficiency.
For Unit 3, items A and B are Infracrions
$3 and item C is a Deficiency.
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Unit 2 6;- Q
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A.
Technical Specification 6.8.1 states in part: " Written procedures
... shall be established, implemented and maintained that meet or r~ i7 9 exceed the requirements and recommendations of... Appendix A of EII.
hk USAEC Regulatory Guide 1.33...." Regulatory Guide 1.33, Appendix A, Section H.1 states in part:
" Procedures... should be provided
[1 ~ S to assure that tools, gauges, instruments, controls, and other i
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measuring... devices are properly... calibrated, and adjusted at
,! ~ 1 specified periods to maintain accuracy.
Specific examples of such j
y, equipment to be calibrated and tested are:
readout instruments,
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interlock permissive and prohibit circuits, alarm devices, sensors,
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signal conditioners, controls, protective circuits...."
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Contrary to the above, as of October 29, 1976, the periodic instru-
'S ment calibration program established by procedure PE-AD-7, Revision 0, dated August 9,1974, was not properly implemented in that (1) 570 of the 687 instruments identified to be calibrated were not calibrated, (2) instrumentation affecting safety related activities was not identffied as requiring calibration, and (3) procedural
- c, step requirements of PE-AD-7 were not complied with.
B.
Technical Specification 6.8.1 requires that written procedures be r
established and implemented.
Check Off List COL-39 was developed pursuant to TS 6.8.1 and establishes the operational alignment of
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the Instrument Air System.
COL-39 requires, in part, that the l
manual isolation valves (IA-11 and IA-11-1) for the automatic g
bypass valve around the regenerative dessicant dryers be locked in i
the open position.
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I.
( Contrary to the above, on October 27, 1976, the inspector found valves IA-11 and IA-11-1 to be open but unlocked. The general problem with the removal of valve locks required by check off lists without the knowledge of supervisory personnel was also identified in Region I Inspection Report 50-247/76-07, Detail 4.c.(7).
C.
- 10 CFR 50, Appendix B, ' Criterion VI, states in part:
" Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto These measures shall assure that documents, including changes, b
are rev*ewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where.the prescribed activity is performed...."
h n) _
Contrary to the above, as of October 29, 1976, drawing 9321-F-2036 and check off list COL-39 had not been changed to reflect the modification made in 1974 to the instrument air system which con-sisted of adding an automatic bypass valve around the refrigerant dryers.
D.
10 CFR 50, Appendix B, Criterion XVI, states in part: "Heasures shall be established to assure that conditions adverse to quality,
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such as... defective... equipt ent... are promptly identified and corrected...."
- ,'y idyt Contrary to the above, on September 12, 1976, the instrument air system dessicant dryer automatic bypass valve was found to be tied in the closed position due to a failed solenoid and. plant personnel I
had not taken prompt action to correct the defective equipment.
The response to this item identified by the licensee nced only address those actions taken or planned to prevent recurrence.
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E.
Environmental Technical Specification 4.VI.1(ii) states, ia part,
~i that: "If the number of fish... killed exceeds 5,000 per day for seven consecutive days... immediate corrective act$.a shall be taken to redace the number killed below those levels."
Contrary to this requirement, on October 17 and 26, 1976, the number of fish killed for seven consecutive days had exceeded 5,000 per day and the immediate corrective actions taken did not reduce the number of fish killed below 5,000 per day.
The response to this item identified by the licensee need only address those actions taken or planned to prevent recurrence.
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J2 nit 3 A.
Technical Specification 6.8.1 states in part: " Written procedures
... shall be established, implemented and maintained that meet or p,
exceed the requirements and recommendations of... Appendix A of P
Pegulatory Guide 1.33...." Regulatory Guide 1.33, Appendix A,
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section H.1 states in part: " Procedures... chould be provided to f
assure that tools, gauges, instruments, controls, and other measuring
... devices are properly... calibrated, and adjusted at specified periods to maintain accuracy. Specific ersmples of such equipment bb to be calibrated and tested are: readout Anstruments, interlock permissive and prohibit circuits, alarm devices, sensors, signal u
conditioners, controls, protectiie circuits...."
f.f[
Contrary to the above, as of October 29, 1976, procedures had not
[1 been written or program implerented to accomplish these tasks.
[:C B.
10 CFR 50, Appendix B, ~ Criterion VI, states in part: "Measurea shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto These measures shall assure that documents, including changes, are reviewed for adequa, and approved for release by authorized J;
personnel and are distributed to and used at the location where the prescribed activity is performed...."
jc s
Contrary to the above, as of October 29, 19/6, drawing 9321-F-20363
.,l and check off list CCL-IA-1 had not been changed to reflect the modification made in 1975 to the instrument air system which consis-ted of adding an automatic bypass valve around the refrigerant dryer.
C.
Environmental Technical Specification 4.1.2a(3)(A)(iii) states, in part, that: "If the number of fish collected... exceeds 5,000 per day for three consecutive days... immediate corrective action shall be taken to reduce the number below these levels...."
j Contrary to this requirement, on October 14 and 21, 1976, the number of fish collected for three consecutive days had exceeded 5,000 per day and the immediate corrective actions taken did not reduce the number of fish collected below 5,000 per day.
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response to this item identified by the licensee need only address those actions taken or planned to prevent recurrence.
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